The accused

• Accused No. 2. Md. Moniruzzaman alias Beltu, BP-7499010053, former Police Commissioner, Rangpur Metropolitan Police, Rangpur
• Accused No. 3. Md. Abu Maruf Hossain alias Titu, BP 7906124376, former Deputy Police Commissioner, RPMP, Rangpur
• Accused No.4. Md. Shah Noor Alam Patwari alias Suman, BP-7911142527, former Additional Deputy Commissioner of Police, RPMP,
• Accused No. 5. Md. Arifuzzaman alias Jibon, BP-7710126839 former Assistant Police Commissioner, Kotwali Zone, RPMP,
• Accused No. 6. Rabiul Islam alias Nayan, BP-8311140416, former Police Inspector (Unarmed), former Officer-in-Charge, Tajhat Police Station, RPMP
• Accused No. 7. Bibhuti Bhushan Roy alias Madhav, SI (unarmed), BP-9220226799, former Camp In-charge, Begum Rokeya University, RPMP, Rangpur

All of the above-named accused persons are fugitives, and hence, charges are framed in absentia.

General Background and Context of the Charges

The accused persons, holding various commanding and operational roles within the Rangpur Metropolitan Police (RPMP), along with associated university authorities and political actors, jointly participated in a widespread and systematic attack against the civilian population-particularly students, academics, and peaceful demonstrators–during the anti-discrimination and quota reform movement, popularly known as the “July Revolution”, which occurred between 1st July to 5th August 2024, centering around Begum Rokeya University, Rangpur.

The evidence reflects that the killings, persecution, suppression, and inhumane acts committed on and around 16th July 2024 formed part of a coordinated state-sponsored operation designed to violently stifle dissent and punish political opposition.

Charge No. l:

Count 1: Crimes Against Humanity – Murder

That you,  [all] pursuant to a common design and joint criminal enterprise, did intentionally order, facilitate, participate in, or personally execute the murder of unarmed student protestor Abu Sayeed on 16th July 2024 near Gate No. 1 of Begum Rokeya University, Rangpur, by opening fire upon peaceful demonstrators.

Your conduct constitutes “murder” as a crime against humanity under Section 3(2)(a) of the Act, punishable under Sections 20(2) and 20A.

Count-2: Crimes Against Humanity – Other Inhumane Acts

That you, through command and operational roles, inflicted severe physical and mental suffering upon peaceful protestors through brutal baton charges, tear gas attacks, arbitrary arrests, and public humiliation, which caused psychological trauma and permanent injuries to many, including minors and women.

These acts amount to “other inhumane acts” and “acts causing great suffering” under Sections 3(2)(a) of the Act, punishable under Sections 20(2) and 20A.

Count-3: Crimes Against Humanity – Persecution on Political Grounds 

That you, jointly and severally, in active collaboration with senior police officers and political authorities, targeted individuals based on their perceived political association with the anti-discrimination movement, including students, teachers, and civilians. Your acts of intimidation, unlawful arrests, surveillance, use of force, and public executions constitute persecution on political grounds, orming part of a systematic pattern of repression, and are thus punishable under Sections 3(2)(a), 20(2), and 20A of the Act.

Charge No. 2:

Count-I: Conspiracy and Participation in Joint Criminal Enterprise

That you, acting pursuant to a premeditated plan with political, university and police authorities, conspired to violently suppress the July Revolution, coordinated brutal force operations and participated in a joint criminal enterprise to commit crimes against humanity. Your collaboration, orders and active engagement contributed directly to the planning and execution of the attacks.

Such acts fall within the meaning of “conspiracy” and “complicity” under Sections 3(2)(g) and 4(3), and are punishable under Sections 20(2) and 20A.

Count-2 : Obstruction to Justice and Tampering with Evidence 

That you, particularly Md. Abu Maruf Hossain alias Titu and Md. Arifuzzaman alias Jibon, following the commission of murder and violence, coerced medical personnel to falsify post-mortem reports and manipulated investigative processes to shield perpetrators and obstruct the course of justice, thereby becoming subsequent participants in crimes against humanity.

These acts constitute “complicity through omission” and/or incitement to commit any such crimes” punishable under Sections 3(2)(h), 4(3), 20(2), and 20A of the Act.

Charge No. 3
Superior Responsibility – Failure to Prevent or Repress Crimes

That you, particularly Md. Moniruzzaman alias Beltu, Md. Abu Maruf Hossain alias Titu, Md. Shah Noor Alam Patwari alias Suman, and Md. Arifuzzaman alias Jibon, while exercising effective command and control over subordinate officers, failed to prevent the commission of the above-mentioned crimes and deliberately refrained from punishing the perpetrators, despite having knowledge of the crimes and authority to act.

Such failure and ommission constitute violations of superior responsibility, as defined under Sections 3(2)(h),4(1), 4(2), and 4(3) of the Act, punishable under Sections 20(2) and 20A.